Iceland – Guernsey FSC say due to changes sort out your EDD by 31 January 2020.

28th November 2019 - The Commission removed Iceland from Appendix C (Equivalent Jurisdictions) of the Handbook on Countering Financial Crime and Terrorist Financing and issued an instruction for all specified business to ensure that full customer due diligence has been applied to all existing business relationships connected to Iceland by 31 January 2020.

This action follows the Financial Action Task Force’s recent public statement identifying strategic deficiencies in Iceland’s regime for tackling money laundering and terrorist financing.  The Commission is taking these steps because it cannot consider, for the purposes of Appendix C, Iceland to be an equivalent jurisdiction with AML/CFT standards and supervision which meet the FATF Recommendations.

At the same time, Instruction No. 03/2019 updating the Business from Sensitive Sources notice is being issued to reflect changes to Part B of the Instruction [It replaces Instruction No. 02/2019 issued on 8 July 2019]

• the addition of Iceland together with Mongolia and Zimbabwe and
• removal of Ethiopia, Sri Lanka and Tunisia.

Further details on these instructions can be found within the instructions and can be accessed through the Financial Crime section of the Commission’s website and via the following links:

1. Instruction No. 03/2019 for Specified Businesses (BFSSN) https://www.gfsc.gg/sites/default/files/uploads/SB%20Instruction%2003-2019.pdf
2. Instruction No. 04/2019 for Specified Businesses (Iceland) https://www.gfsc.gg/sites/default/files/uploads/SB%20Instruction%2004-2019.pdf

The Updated Appendix C can be found here

• https://www.gfsc.gg/sites/default/files/uploads/20191129%20-%20Appendix%20C%20-%20Equivalent%20Jurisdictions.pdf

By way of reminder

1. Appendix C to the GSY Handbook was established to reflect those countries or territories which the Commission considers require regulated FSBs, and in limited circumstances PBs, to have in place standards to combat ML and FT consistent with the FATF Recommendations and where such businesses are appropriately supervised for compliance with those requirements.
2. Appendix C is reviewed periodically with countries or territories being added or removed as appropriate.
3. The fact that a country or territory has requirements to combat ML and FT that are consistent with the FATF Recommendations means only that the necessary legislation and other means of ensuring compliance with the FATF Recommendations are in force in that country or territory.  It does not provide assurance that a particular overseas business is subject to that legislation, or that it has implemented the necessary measures to ensure compliance with that legislation.
4. The firm is not obliged to deal with regulated FSBs in the jurisdictions listed above as if they were local, notwithstanding that they meet the requirements identified in this Appendix.  The firm may, in deciding whether or not to deal with a regulated FSB or PB, impose higher standards than the minimum standards identified in this Handbook where it considers this necessary.